Model 231

The organizational, management and control model according to the requirements laid down in Legislative Decree 231/2001 adopted by SAES Getters S.p.A.

According to the Legislative Decree 231/2001, introducing the organizational, management and control model (hereinafter “Model”), Saes Getters S.p.A. (hereinafter “SAES”), sensitive to the need to ensure conditions of correctness and transparency in the conducting of company affairs and activities, and to the protection of its position and image, the expectations of its shareholders and the work of its employees, has decided to adopt its organizational, management and control instruments to the requirements expressed by the Decree.
This decision has been taken in the belief that the adoption of the Model may represent not only an effective way of raising the awareness of all those who work on behalf of SAES with regard to the correct and consistent behaviors that they must adopt in the performance of their duties, but also a necessary mean of preventing the risk of the crimes specified in the Decree being committed. In particular, through the adoption and regular update of the Model, the Board of Directors aims at pursuing the following principal objectives:

to raise the awareness of all those who work on behalf of SAES in sensitive activities (understood to mean activities where the offences identified in the Decree may be committed), that if they violate the provisions contained therein, they may be subject to disciplinary and/or contractual consequences as well as criminal and administrative penalties that may be inflicted against them and also against SAES;

to reinforce the fact that these forms of unlawful behavior are strongly condemned by SAES, not only because they are against the law but also because they run contrary to the ethical principles which SAES wishes to adhere to in conducting its business;

to enable SAES, thanks also to monitoring of the areas of activity at risk, to reasonably prevent or stop these crimes from being committed and to sanction behaviors that do not comply with the Model.

The Model was first adopted by Company's Board of Directors resolution of December 22, 2004, updated and integrated during last four years to take into account the changes to the Decree and especially the new types of offences defining the administrative responsibility introduced by.

The Model adopted adheres to the Guidelines published by Confindustria.